15 January 2024 – Income Tax Act, 1962
Unitrans Holdings Limited v CSARS (A3094/2022) [2024] ZAGPJHC 3 (9 January 2024)
Appeal from the Tax Court – whether interest expenditure is tax deductible, as having been incurred in the course of carrying out ‘any trade’ and in the production of income – section 24J(2) of the Income Tax Act – the taxpayer trading as an investment holding company – the interest expenditure claimed not closely linked to its income earning operations as an investment holding company – the purpose of the expenditure was not to produce income but to further the interest of the subsidiaries – therefore, the expenditure was not incurred in the production of the taxpayer’s income.
Appeal dismissed with costs.
